Subject: File No. 4-606
From: Janice Ruth Nickell, LUTCF
Affiliation: Registed Account Representative

July 30, 2010

The suitability standard governing broker-dealers and registered representatives is a robust and heavily enforced standard. I don't think that the fiduciary standard governing investment advisers is as good or applied and enforced as strenuously as the standards that we are governed under now.

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.
I hold a series 6 and 63 licenses that I continue to keep in force by my hours of continuing education and passing State tests.
I must comply with the standards of my company and with the state each year.
The paperwork involved in compliance is already overly time consuming for the compensation that I recieve. If more paperwork is involved in these new rules, then it will no longer be cost effective to do business.
I think that the compliance that we have now is more than adequate to protect the public as long as the public is educated to look for members of NAIFA and work with licensed professionals.
I am so busy now filling out all the proper compliance requirements I fear that more regulations will impact my ability to serve my clients in a timely manner.
If the cost of doing business increases minimally, it will still be too much.
If the business moves to a fee-only model I doubt that this will result in better, unbiased advice.
I don't want to be forced into a fee based model simply to protect myself at the expense of my clients.
I know that I serve my clients needs to the best of my ability, and that the companies that appoint me have confidence in their compliance departments and my abilities to adhere to their rules and regulations. I don't think that we need more red tape. I don't think that more red tape will help the client or the representatives or the broker/dealers. It will simply become so cumbersome that there won't be any registered representatives left to help the clients.